On December 03, 2013 a Party Discovery was filed involving a dispute between Karidis-Koepke, Nancy, Koepke, Harold, and A.B.C. Mobile Systems, A.B.C. Mobile Systems, Individually And As, American Honda Motor Co. Inc., Bell Industries, Inc., Bell Industries Inc., Individually And As, Belnortel Corporation, D.B.A. A.B.C. Mobile Brake, Borgwarner Morse Tec, Inc., Borgwarner Morse Tec Inc., Individually And As, Burlingame Auto Supply, Continental Automotive Systems, Inc., Cooper Industries Llc, Cooper Industries, Llc, Individually And As, Don L. Morris, Inc., First Doe Through Four Hundredth Doe, Inclusive, Fmc Corporation-John Bean Automotive Equipment, Fmc Technologies, Inc., Individually And As, Folsom Auto Supply, Ford Motor Company, Foreland Parts, Inc.,, Genuine Parts Company, H.M. Royal, Inc., Honeywell International, Inc., Fka Allied Signal,, Kelsey-Hayes Company, Lear Siegler Diversified Holdings Corp.,, Les Vogel Chevrolet Company, Metropolitan Life Insurance Company, Morton International, Inc., A Rohm And Haas, Morton International, Llc, Formerly Known As, National Automotive Parts Association, Parker Hannifin Corporation, Parker Hannifin Corporation, Individually And As, Pneumo Abex Llc, Individually And As Successor In, Rox Automotive, Shell Oil Company, Specialty Foreign Auto Parts, Inc., Erroneously, The Budd Company, Thyssenkrupp Budd Company Sued As "The Budd, Toyota Motor Sales, U.S.A., Inc., University Distributors, Inc., Erroneously Sued, Volkswagen Group Of America, Inc., W. Berry Hurley Corporation, D.B.A. Federal Auto, Karidis-Koepke, Nancy, Koepke, Harold, The Hertz Corporation, for civil in the District Court of San Francisco County.
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28 CARROLL, BURDICK & McDonouce LLP crosses Las ‘SAN FRANCISCO Garrett Sanderson III, Bar No. 131026 gsanderson@cbmlaw.com Peter H. Cruz, Bar No. 220850 ELECTRONICALLY peruz@cbmlaw.com FILED CARROLL, BURDICK & McDONOUGH LLP Superior Court of California, Attorneys at Law County of San Francisco 44 Montgomery Street, Suite 400 San Francisco, California 94104 MAR 04 2014 Telephone: 415.989.5900 BY: WILLIAM TRUPEK Facsimile: 415.989.0932 Deputy Clerk Attorneys for Defendant Volkswagen Group of America, Inc. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217 KOEPKE, NOTICE OF VWGOA’s MOTION FOR Plaintiffs, PROTECTIVE ORDER TO PRECLUDE DEPOSITION OF ITs 85-YEAR OLD FORMER v. PRESIDENT AND FOR MONETARY SANCTIONS FORD MOTOR COMPANY, et al., Date: March 26, 2014 Time: 9:00 a.m. Defendants. Dept.: 503 Action Filed: December 3, 2013 Trial Date: June 16, 2014 TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on March 26, 2014, at 9:00 a.m., or as soon thereafter as this matter may be heard, in Department 503 of the above-captioned court, which is located at 400 McAlister Street, San Francisco, California 94102, Volkswagen Group of America, Inc., will, and hereby does, move pursuant to Code of Civil Procedure section 2025.420 for a protective order barring plaintiffs from deposing J. Stuart Perkins, the 85 year-old former president of Volkswagen Group of America, Inc., on grounds that he does not have any knowledge about asbestos that may have been previously contained in some automotive parts, he is elderly, and plaintiffs cannot show that he has special or unique personal knowledge and that they have exhausted less intrusive means of discovery, including deposing the company and directing written discovery to the CBM-PRODUCTS\SF618851-1 Case No. CGC-13-276217 NOTICE OF VWGOA’S MOTION FOR PROTECTIVE ORDER TO PRECLUDE DEPOSITION OF ITS 85 YEAR-OLD FORMER PRESIDENT AND FOR MONETARY SANCTIONS1 || company to ascertain if Mr. Perkins has relevant personal knowledge. As a result, Volkswagen 2 || Group of America, Inc., also moves for an award of monetary sanctions pursuant to Code of Civil 3 || Procedure sections 2023.010 and 2025.420(h) in the sum of $4,353.00 from Joseph Satterley and 4 || Kazan, McClain, Satterley & Greenwood. This motion for a protective order and for sanctions is based on this notice, the declarations of J, Stuart Perkins and Garrett Sanderson III, and the memorandum of points and authorities filed NI A iw and served herewith, and on such other evidence of which the court may take notice at the hearing. 8 || Dated: March “f , 2014 CARROLL, BURDICK & McDONOUGH LLP " By ZN. 1 Barrett Sanderson ‘Attorneys for Defendant Volkswagen Group of 2 America, Inc. 14 16 28 CARROLL, BURDICK & CBM-PRODUCTS\SF618851-1 -2- Case No. CGC-13-276217 MeDoNouGH LLP ATTOANENS ATLA NOTICE OF VWGOA’S MOTION FOR PROTECTIVE ORDER TO PRECLUDE DEPOSITION OF ITS 85 YEAR-OLD FORMER SAN FRANCISCO PRESIDENT AND FOR MONETARY SANCTIONS